SIME DARBY ENGINEERING SDN BHD,DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

SIME DARBY ENGINEERING SDNBHD,MALAYSIA vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

SIME DARBY ENGINEERING SDN BHD,GURGAON vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

NATIONAL OILWELL VARCO PTE LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

NATIONAL OIL WELL VARCO PTE. LTD (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE. LTD),MAHARASHTRA vs. THE DEPUTY DIRECTOR OF INCOME TAX CIRCLE-1( INTERNATIONAL TAXATION ), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

NATIONAL OILWELL VARCO PTE. LTD.,MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CI9RCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

NATIONAL OILWELL VARCO PTE. LTD. (FORMERLY KNOWN AS VARCO INTERNATIONAL PTE LTD.),MUMBAI vs. DCIT (INTERNATIONAL TAXATION), CIRCLE-2, DEHRADUN

In the result, captioned appeals of the Assessee in ITA No

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Through Virtual Mode]

Transfer Pricing Officer (TPO), the time) limit available stands extended by another 12 months, and in the present case, the upper time limit for completion of assessment proceedings would expire on 30.09.2021. 18. In the present case, the final assessment order passed by the A.O. under Section 143(3

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer 3(2)(2) (“TPO”) for determination of arm’s length price of the specified domestic transactions (“SDT”) / international transactions undertaken by the Applicant. 9. The TPO vide order dated 30 January 2019 held that the applicant has earned more than ordinary profits from its Section

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION, MUMBAI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

3. The assessee/respondent appears to have filed its twin returns on 30th November, 2011 and 30th November, 2012 declaring income(s) of Rs.8,90,50,35,760/- and Rs.9,61,7283,910/-; assessment year-wise, respectively. The Assessing Officer thereafter made section 92CA reference(s) to the Transfer Pricing

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, DEHRADUN vs. BG EXPLORATION PRODUCDTION INDIA LIMITED, MUMBAI

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal(Through Video Conferencing)

3. The assessee/respondent appears to have filed its twin returns on 30th November, 2011 and 30th November, 2012 declaring income(s) of Rs.8,90,50,35,760/- and Rs.9,61,7283,910/-; assessment year-wise, respectively. The Assessing Officer thereafter made section 92CA reference(s) to the Transfer Pricing

M/S. THDC INDIA LIMITED,RISHIKESH vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, appeal of the assessee is allowed

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] M/S. Thdc India Ltd. Vs Pcit Ganga Bhawan, Aaykar Bhawan, Pragatipuram, Bye Pass 13 A, Subhash Road, Road, Rishikesh, Uttarakhand Uttarakhand-249201 Pan-Aaact7905Q Appellant Respondent Assessee By Shri Jeetan Nagpal, Ca Shri Sanjay Arora, Ca & Ms. Pallavi, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 08.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 27.03.2022 By Ld. Pr. Commissioner Of Income Tax, Dehradun [“Ld. Pcit”] Passed U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 30.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Joint Venture Company Of Government Of India & Government Of Uttar Pradesh & Engaged In The Business Of Generation & Supply Of Hydro- Electric As Well As Wind Power & Also Engaged In Construction Of Hydro Power Plants. The Return Of Income Was Filed On 30.10.2017, Declaring Total Income Of Inr 6,84,04,420/- After Claiming Deduction U/S 80-Ia Of The Act Of Inr 948,40,76,282/-. The Book Profits Was Shown At Inr 7,84,96,09,382/- & Mat Of Inr 1,67,52,32,236/- Was Paid. The Case Of The Assessee Was Selected For Scrutiny & After Considering The Submissions Made, Total Income Was Assessed At Inr 4,63,78,80,698/- By Making Disallowance Out Of Deduction Claimed U/S 80-Ia Of The Act To The Extent Of Inr 211,15,54,378/- & Further Making Addition Of Inr 245,79,21,900/- On Account Of Late Payment Surcharge On Outstanding Debtors For The Period Of 10 Months Holding The Same As Taxable On Accrual Basis & No Deduction U/S 80Ia Was Allowed On Such Addition.

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

M/S. UJVN LIMITED,DEHRADUN vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, DEHRADUN

In the result, the appeal of the Assessee is allowed

Bench: Sh. C. N. Prasad & Shri M. Balaganesh(Through Video Conferencing) M/S. Ujvn Limited, Vs. The Principal Commissioner C/O. Mn/S. Rra Taxindia, Of Income, D-28, South Extension, Aayakar Bhawan, 13A, Part-I, Subhash Road, Dehradun New Delhi (Appellant) (Respondent) Pan: Aaacu6672R Assessee By : Dr. Rakesh Gupta, Adv Shri Somil Aggarwal, Adv Revenue By: Shri N. S. Jangpangi, Cit Dr Date Of Hearing 24/08/2023 Date Of Pronouncement 15/09/2023

transfer price of lignite and sale price of electricity in computing relief under Section 801A/80IB? 2. If the answer to the question No. 1 is in favour of appellant, whether the notional tax reimbursement in the case of Unit VII of Thermal Power Station II whose entire income is deductible u/s 80IA should also be taken into account for computing

ASSISTANT COMMISSIONER OF INCOME TAX, HALDWANI vs. DELTA POWER SOLUTIONS (INDIA) PVT. LTD., (NOW), DELTA ELECTRONICS INDIA PVT. LTD., GURGAON

Accordingly. This Revenue’s appeal ITA Nos. 5543/Del/2018 is partly allowed for statistical purposes

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2013-14 Vs. M/S. Dcit, Delta Power Solution Circle-1, (India) Pvt. Ltd., Haldwani Plot No. 38, Phase-1, Sector-5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With C.O. No. 38/Del/2019 [Arise Out Of Ita No.5543/Del/2018] Assessment Year: 2013-14 Vs. Dcit, Delta Power Solution (India) Pvt. Ltd., Circle-1, Plot No. 38, Phase-1, Sector- Haldwani 5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With Assessment Year: 2013-14 Vs. Delta Power Solution (India) Acit, Haldwani Pvt. Ltd. (Now, Delta Electronics India Pvt. Ltd.) Plot No. 43, Sector-35, Hsiidc, Gurgaon Pan: Aaccd5896N (Appellant) (Respondent)

section 143(3)/92C(4) of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. 2. Heard both the parties. Case files perused. The Revenue’s main appeal ITA No.5543/Del/2018 raises the following grounds: 1. Whether the Ld. CIT(A) was justified in rejecting the comparable companies selected by the Ld. TPO on the basis of functional

DCIT,CIRCLE-1, HALDWANI vs. DELTA POWER SOLUTION INDIA PVT. LTD., U S NAGAR

Accordingly. This Revenue’s appeal ITA Nos. 5543/Del/2018 is partly allowed for statistical purposes

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2013-14 Vs. M/S. Dcit, Delta Power Solution Circle-1, (India) Pvt. Ltd., Haldwani Plot No. 38, Phase-1, Sector-5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With C.O. No. 38/Del/2019 [Arise Out Of Ita No.5543/Del/2018] Assessment Year: 2013-14 Vs. Dcit, Delta Power Solution (India) Pvt. Ltd., Circle-1, Plot No. 38, Phase-1, Sector- Haldwani 5, Iie, Pantnagar, Rudrapur, Distt. Us Nagar, Udham Singh Nagar, Uttarakhand Pan: Aaccd5896N (Appellant) (Respondent) With Assessment Year: 2013-14 Vs. Delta Power Solution (India) Acit, Haldwani Pvt. Ltd. (Now, Delta Electronics India Pvt. Ltd.) Plot No. 43, Sector-35, Hsiidc, Gurgaon Pan: Aaccd5896N (Appellant) (Respondent)

section 143(3)/92C(4) of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. 2. Heard both the parties. Case files perused. The Revenue’s main appeal ITA No.5543/Del/2018 raises the following grounds: 1. Whether the Ld. CIT(A) was justified in rejecting the comparable companies selected by the Ld. TPO on the basis of functional

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

3 The Ld CIT(A) erred in facts and in law, by ignoring the Appellants Profit Attribution Report [duly maintained by the Appellant in accordance with provisions of section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value